Committee on the Elimination of
Discrimination against Women
Concluding observations on the third to fourth periodic report of Turkmenistan adopted by the Committee at its fifty-third session (1-19 October 2012)
1.The Committee considered the combined third and fourth periodic report of Turkmenistan (CEDAW/C/TKM/4-5) at its 1085th and 1086th meetings, on 11 October 2012 (see CEDAW/C/SR.1085 and 1086). The Committee’s list of issues and questions is contained in CEDAW/C/TKM/Q/3-4 and the responses of the Government of Turkmenistan are contained in CEDAW/C/TKM/Q/3-4/Add.1.
2.The Committee takes note of the State party’ submission of its combined third and fourth periodic report, which in general, followed the Committee’s guidelines for the preparation of reports, however, it regrets that the report was overdue and lacked recent data, disaggregated by sex. The Committee expresses its appreciation to the State party for its oral presentation, which included a power point presentation, the written replies to the list of issues and questions raised by its pre-session working group and the further clarifications to the questions posed orally by the Committee.
3.The Committee commends the State party’s high level and gender balanced delegation, headed by H.E., Ms.Yazdursun Gurbannazarova, Director of Turkmen National Institute of Democracy and Human Rights under the President of Turkmenistan, which included three Deputy Ministers, one member of Parliament and the Chairperson of Women’s Union of Turkmenistan. The Committee appreciates the constructive dialogue that took place between the delegation and the members of the Committee, while noting that answers to some questions were vague and some questions were left unanswered.
4.The Committee welcomes the progress achieved since the adoption of its previous concluding observations in 2006, including the legislative reforms that have been undertaken and the adoption of a range of legislative measures. Specific reference is made to the:
(a)Family Code (2012);
(b)Criminal Code (2010);
(c)Penal Enforcement Code (2011);
(d)Legal Profession and Legal Practice Act (2010)
(e) Code of Criminal Procedure (2009);
(f)Labour Code (2009);
(g)Education Act (2009);
(h)Social Security Code (2007);
(i)Human Trafficking Act (2007);
(j)Law on State Guarantees of Equality of Women (2007);
(k)Law on Microfinance Organizations and Micro financing (2011).
5.The Committee welcomes the adoption of the following policies:
(a)National HIV Strategy (2012-2016);
(b)National Early Development of Child Programme (2011-2015);
(c)National Programme on Fighting Illicit Trafficking of Drugs, Psychotropic Substances, Precursors and Rendering Assistance to Drug Addicts (2011-2015).
6.The Committee notes with appreciation the establishment in 2007, of an Interdepartmental Commission on compliance with Turkmenistan’s international human rights obligations, including the Convention.
7.The Committee welcomes the accession by the State party to the:
(a)Optional Protocol to the Convention (in 2009);
(b)International Convention on the Rights of Persons with Disabilities (in 2008);
(c)Optional Protocol to the International Convention on the Rights of Persons with Disabilities (in 2010);
(d)Convention on Status of Statelessness Persons (in 2011);
(e)Convention on the Reduction of Statelessness (in 2012)
C.Principal areas of concern and recommendations
8.The Committee recalls the obligation of the State party to systematically and continuously implement all the provisions of the Convention and views the concerns and recommendations identified in the present concluding observations as requiring the priority attention of the State party between now and the submission of the next periodic report. Consequently, the Committee urges the State party to focus on those areas in its implementation activities and to report on actions taken and results achieved in its next periodic report. The Committee calls upon the State party to submit the present concluding observations to all relevant ministries, to the Parliament, and to the judiciary, so as to ensure their full implementation.
9. While reaffirming that the Government has the primary responsibility and is particularly accountable for the full implementation of the obligations of the State party under the Convention, the Committee stresses that the Convention is binding on all branches of Government, and it invites the State party to encourage the Parliament, in line with its procedures, where appropriate, to take the necessary steps with regard to the implementation of the present concluding observations and the Government’s next reporting process under the Convention.
Visibility of the Convention, the Optional Protocol and the Committee’s general recommendations
10.The Committee welcomes the ratification by the State party of the Optional Protocol to the Convention on 20 May 2009. The Committee is, however, concerned at the general lack of awareness about the concept of substantive gender equality and of the Committee’s general recommendations in the State party. It is further concerned that women themselves, especially those in rural and remote areas, are not aware of their rights under the Convention, and thus lack the necessary information to claim their rights.
11. The Committee calls on the State party to:
(a) Take the necessary steps to ensure the adequate dissemination of the Convention and the Committee’s general recommendations and views under the Optional Protocol among relevant stakeholders, including Government ministries, parliamentarians, the judiciary, law enforcement officers and community leaders, so as to create awareness of women’s human rights and establish firmly in the country a legal culture supportive of women’s equality and non-discrimination;
(b) Take all appropriate measures to enhance women’s awareness of their rights and the means to enforce them, in particular, in rural and remote areas, including through providing women with information on the Convention, through the use of all appropriate measures, such as the cooperation with civil society and the media.
Legal status of the Convention and definition of discrimination against women
12.The Committee is concerned that, although article 6 of the new Constitution expressly “recognizes the priority of the universally accepted norms of international law” and provides that in the event of a conflict “the rules of international treaty will apply”, the Committee regrets that the Convention and its general recommendations are not being sufficiently referred to in the national court decisions to give visibility to the standards and norms of the Convention. The Committee further expresses its concern that the definition of discrimination against women in the State party’s Constitution makes reference only to civil rights, and that it is therefore not in line with article 1 of the Convention. The Committee further reiterates its concern that gender neutral laws may perpetuate indirect discrimination against women.
13. The Committee urges the State party:
(a) To take measures to ensure that the provisions of the Convention are fully applicable in the domestic legal system;
(b) To train the judiciary and the legal profession on the Convention and the Committee’s general recommendations and encourage them to refer to the Convention and the norms and standards contained therein in order give it greater visibility;
( c ) To include in the Constitution or in the Law on State Guarantees on Gender Equality the principle of equality with respect to all rights, including civil, political, economic, social and cultural rights, and a definition of discrimination against women in line with article 1 of the Convention.
National machinery for the advancement of women
14.The Committee expresses its concern that it did not obtain a clear picture of the State party’s national machinery for the advancement of women. While noting the existence of the Institute for Democracy and Human Rights, the Women’s Union and the Inter-agency Commission, the Committee is concerned that the State party’s machinery is fragmented, as well as about the lack of information on its mandates, authority, human and financial resources and capacity to ensure that gender equality policies are properly developed and fully implemented throughout the work of all ministries and Government offices. The Committee is further concerned at the absence of a National Action Plan for implementation of the Convention.
15. The Committee encourages the State party:
(a) To establish one centralized national machinery for the advancement of women with a clearly defined mandate and responsibilities and provide it with adequate human, financial and technical resources for it to coordinate and work effectively for the promotion of gender equality and gender mainstreaming;
(b) To provide training o n women’s rights , to women and men working in the national machinery for the advancement of women;
(c) To adopt a National Action Plan for the implementation of the Convention , with a focus on the implementation of the present concluding observations ;
(d) To strengthen its impact assessment mechanisms so as to ensure that its gender equality policies are properly monitored and evaluated and their implementation assessed.
National human rights institution
16.The Committee notes with concern that the State party has not yet established an independent national human rights institution with a wide mandate to protect and promote women’s human rights, in accordance with the principles relating to the status of national institutions for the promotion and protection of human rights ( Paris Principles), despite the recommendation to do so made during the universal periodic review of Turkmenistan in 2009 (see A/HRC/10/29) and the recommendation made by the Committee on Economic, Social and Cultural Rights in 2011 (E/C.12/TKM/CO/1, para. 7).
17. The Committee urges the State party to establish, within a clear time frame , an independent national human rights institution, in accordance with the Paris Principles , whose competencies should include issues related to the equality of women and men .
Temporary special measures
18.The Committee reiterates its concern at the State party’s apparent lack of understanding of the purpose and need for temporary special measures in accordance with article 4, paragraph 1, of the Convention. In this regard, the Committee is concerned that temporary special measures are not systematically applied as a strategy necessary to accelerate the achievement of substantive equality of women and men in areas covered by the Convention, especially those of employment, participation in political and public life and others in which women are underrepresented or disadvantaged.
19. The Committee encourages the State party to adopt temporary special measures, in accordance with article 4 , paragraph 1 of the Convention, as interpreted in the Committee’s general recommendation No. 25 (2004) , in all areas covered by the Convention in which women are underrepresented or disadvantaged. To that end, it recommends that the State party:
(a) Set time-bound targets and allocate sufficient resources for the implementation of strategies, such as outreach and support programmes, the creation of quotas and other proactive and results-oriented measures aimed at achieving substantive equality of women and men in all areas, in particular in the areas of employment and participation in political and public life;
(b) Raise awareness among Members of Parliament, Government officials, employers and the general public about the need for temporary special measures and provide comprehensive information on the use of such measures and their impact in its subsequent periodic report.
Stereotypes and harmful practices
20.While noting the reassurances of the State party’s delegation, expressed during the dialogue, that there is no legal or administrative provision or State policy in the State party imposing a dress code on women, and that no woman or girl has been expelled from work or educational institution for failure to wear the national dress, shawl or skull-cap takhya, the Committee continues to be seriously concerned about attitudes and policies reinforcing discriminatory traditional norms, harmful practices and patriarchal attitudes and deep-rooted stereotypes regarding the roles and responsibilities of women and men in all spheres of life. The Committee is further concerned at the State party’s limited efforts to tackle such discriminatory practices. The Committee is concerned that such customs and practices perpetuate discrimination against women and girls and that they are reflected in women’s disadvantaged and unequal status in many areas, including education, public life and decision-making, and in the persistence of violence against women, and that, to date, the State party has not taken sustained measures to modify or eliminate stereotypes and negative traditional values and practices.
21. The Committee urges the State party:
(a) To put in place, without delay, a comprehensive strategy to modify or eliminate patriarchal attitudes and stereotypes that discriminate against women, in conformity with the provisions of the Convention. Such measures should include efforts, in collaboration with civil society and community leaders, to educate and raise awareness of the subject, targeting women and men at all levels of society;
(b) To expand public education programmes, in particular in rural and isolated areas;
(c) To use innovative measures that target the media to strengthen understanding of the equality of women and men and to use the education system to enhance a positive and non-stereotypical portrayal of women;
(d) To monitor and review the measures taken so as to assess their impact and to take appropriate action.
Violence against women
22.The Committee expresses its deep concern at the absence of specific legislation to deal with violence against women, in particular domestic and sexual violence, as well as at the lack of information and statistical data on its nature, extent and causes. The Committee is deeply concerned that violence against women appears to be socially legitimized and accompanied by a culture of silence and impunity, and that cases of violence are therefore underreported, it being considered a private issue that should remain within the family.
23. The Committee urges the State party to give priority attention to combating violence against women and girls and adopt comprehensive measures to address such violence, in accordance with its general recommendation No.19 (1992) on violence against women , including t o:
(a) Expeditiously adopt a comprehensive law addressing all forms of violence against women, including domestic and sexual violence, and ensuring that women and girls who are victims of violence have access to immediate means of redress and protection and further ensuring that perpetrators are prosecuted and punished;
(b) Develop a comprehensive national plan to combat all forms of violence against women;
(c) Raise public awareness, through the media and educational programmes and to provide mandatory training for judges, prosecutors, police officers, health-service providers, journalists and school staff in order to ensure that they are sensitized to all forms of violence against women and girls and can provide adequate gender-sensitive support to victims;
(d) E ncourage women to report incidents of domestic and sexual violence by de-stigmatizing victims and raising awareness about the criminal nature of such acts and to provide adequate assistance and protection to women victims of violence by establishing shelters, especially in rural areas, and enhancing cooperation with non-governmental organizations providing shelter and rehabilitation to victims;
(e) C ollect statistical data on domestic and sexual violence disaggregated by sex, age, nationality and relationship between victim and perpetrator, and undertake studies and/or surveys on the extent of violence against women and its root causes.
Trafficking and exploitation of prostitution
24.While noting the adoption in 2007 of the Human Trafficking Act and several joint projects undertaken by the State party with International Organization for Migration to combat trafficking, the Committee is concerned at the absence of a National Plan of Action to combat trafficking and exploitation of prostitution. The Committee is further concerned at the lack of statistical data, disaggregated by sex and location, on trafficking and exploitation of prostitution in the State party. The Committee is also concerned about the lack of efforts to prevent the exploitation of prostitution and to address its root causes, and the lack of protection and services available to victims of exploitation.
25. The Committee calls upon the State party to fully implement article 6 of the Convention and:
(a) To adopt, within a concrete timeframe, a National Plan of Action in order to ensure effective implementation of the Human Trafficking Act;
(b) To include in its subsequent report information and data on the prevalence of exploitation of prostitution and trafficking;
(c) To conduct studies and surveys for the above purpose, including on the prevalence of prostitution, and to seek international assistance as required;
(d) To increase efforts at international, regional and bilateral cooperation with countr ies of origin, transit and destination to prevent trafficking through information exchange and to harmonize legal procedures aiming at prosecution of traffickers;
(e) To address the root causes of trafficking and prostitution, including poverty, in order to eliminate the vulnerability of girls and women to sexual exploitation and trafficking, and to strive to ensure the recovery and social integration of victims, by providing them with shelters and assistance.
Participation in political and public life
26.While noting that women in the State party occupy a few ministerial positions and are well represented in the judiciary, the Committee is concerned at the underrepresentation of women at all levels of political and public life, in particular in Parliament (17 per cent), Regional People’s Councils (16.67 per cent), District and Municipal People’s Councils (20.21 per cent) and the diplomatic service. The Committee is also concerned that no temporary special measures have been envisaged in order to remedy this situation. The Committee is further concerned that systematic barriers such as negative cultural attitudes, lack of an adequate quota system, insufficient capacity-building for potential candidates, limited financial resources and lack of logistical support impede women’s equal participation in political life.
27. The Committee calls upon the State party:
(a) To consider the use of temporary special measures in accordance with article 4 , paragraph 1 of the Convention and the Committee’s general recommendations No s . 23 (1997) and25 (2004) , and to establish adequate quotas with the aim of accelerating the equal representation of women in all areas of public and professional life, especially in decision-making positions and in local administration;
(b) To ensure that women enjoy equal opportunities to participate in political and public life, including in the planning, implementation, monitoring and evaluation of development policies and community projects;
(c) To provide training on gender equality for politicians, journalists, teachers and community leaders, especially men, to enhance the understanding that full, equal, free and democratic participation of women on an equal basis with men in political and public life is a requirement for the full implementation of the Convention.
Civil society and non-governmental organizations
28.The Committee remains concerned at the lack of information about civil society organizations, such as women’s and human rights organizations, and the strict legal and procedural requirements for the registration of non-governmental and civil society organizations, as well as restrictions imposed on their activities, in particular with respect to those projects and programmes supported by foreign donors.
29. The Committee reiterates its previous recommendation (CEDAW/C/TKM/CO/2, para. 21) and urges the State party to provide an enabling and conducive environment for the establishment and active involvement of women’s and human rights organizations in enhancing the implementation of the Convention in the State party.
30.The Committee welcomes the State party’s Education Act adopted in August 2009 which guarantees and protects citizens’ constitutional right to education and the increase of salaries in the education sector and of student grants by 40 per cent. The Committee also welcomes the 10 year education introduced in 2007-2008. The Committee is, however, concerned at the lack of data on enrolment of boys and girls in pre-school, primary, secondary and tertiary levels, as well as on the dropout rates and their causes. The Committee is also concerned that despite the slight increase of enrolment of girls in non-traditional areas (24.4 per cent of girls in the Oil and Gas Institute, 23.6 per cent in the Institute of Energy Studies, 41.6 per cent in the Institute of the Ministry of Foreign Affairs), the traditional views of both students and teachers orient female students into areas of study perceived as appropriate to their social roles and participation in public life.
31. The Committee urges the State party to enhance its compliance with article 10 of the Convention and to raise awareness of the importance of education as a human right and as the basis for the empowerment of women. To this end, it urges the State party:
(a) To t ake immediate steps to implement measures to ensure equal access for girls and women to all levels of education and retention of girls in school, including through temporary special measures in accordance with article 4, paragraph 1, of the Convention and the Committee’s general recommendation No. 25 (2004) ;
(b) To address barriers to the education of women and girls, such as negative cultural attitudes and excessive domestic duties, to take steps to reduce and prevent dropouts among girls and to strengthen the implementation of re ‑entry policies enabling girls who drop out to return to school;
(c) To implement measures to eliminate traditional stereotypes and structural barriers that might deter girls from enrolling in science subjects at the secondary and tertiary levels;
(d) To step up efforts to provide girls with career counselling that orients them to non-traditional career paths, in particular in technical-vocational areas.
32.The Committee is concerned at the continuing vertical and horizontal occupational segregation and the persistent wage gap between women and men in some areas. The Committee is also concerned about the potential negative impact on women of the Labour Code and the Presidential Decree No.10732 of 25 December 2009, which appear to be overly protective of women as mothers and provide restrictions on working time, overtime work and night work for women, and therefore limit women’s economic opportunities in a number of areas. The Committee is further concerned that 52.8 per cent of women in the State party work in the informal sector, and in the rural areas they constitute 65.3 per cent.
33. The Committee urges the State party:
(a) To strengthen the efforts to eliminate occupational segregation, both horizontal and vertical, and to adopt measures to narrow and close the wage gap between women and men by applying job evaluation schemes in the public sector connected with wage increases in sectors dominated by women;
(b) To establish a regulatory framework for the informal sector with a view to providing women with access to social security and other benefits;
(c) To carefully review and analyse the impact of the Labour Code and the Presidential Decree No.10732 on women’s opportunities in the labour market, and make necessary amendments to ensure the health and safety of all workers, encourage sharing of family responsibilities between women and men, and contribute to the elimination of stereotypes and traditional attitudes that discriminate against women;
(d) Adopt temporary special measures in accordance with article 4, paragraph 1, of the Convention and the Committee’s general recommendation No. 25 (2004) , aimed at achieving de facto equal opportunities for men and women in the labour market.
34.While welcoming the progress achieved by the State party in reducing maternal and child mortality and the adoption of the new National Reproductive Health Strategy in Turkmenistan for 2011 – 2015 and noting special attention given to the area of reproductive health, the Committee is concerned that the fees for medical services have increased while the quality remains poor, as patients need to bring to the hospital their own bedding, supplies and medications, as well as to pay additional fees. While noting the development of the third national HIV program 2012 – 2016 in collaboration with the United Nations partners in the State party, the Committee is concerned at the lack of information and data, disaggregated by sex and regional location, on the prevalence of the HIV/AIDS.
35. The Committee urges the State party:
(a) To take all measures necessary to improve women’s access to quality health care and health-related services, within the framework of the Committee’s general recommendation No. 24 (1999) ;
(b) To widely promote education on sexual and reproductive health and rights, targeting adolescent girls and boys and paying special attention to early pregnancy and control of sexually transmitted infections, including HIV/AIDS.
Women in detention
36.The Committee is concerned at the situation in Dashoguz prison with regard to overcrowded cells, prisoners working under harsh climate conditions, as well as violence and abuse perpetrated against female inmates by prison officers and at the lack of adequate mechanisms for, and an environment conducive to the submission of complaints. The Committee is further concerned at the multiple discrimination suffered by certain disadvantaged groups of women, who are exposed to criminal prosecution and social stigma, thereby preventing their enjoyment of all rights under the Convention.
37. The Committee calls upon the State party to :
(a) E nsure decent living and working conditions and protection of women against violence and other forms of abuse in places of detention and establish clear procedures for complaints, as well as mechanisms for monitoring and oversight ;
(b) Ensure that allegations by women detainees about discriminatory treatment and gender-specific abuse are effectively investigated and perpetrator are prosecuted and punished.
Marriage and family relations
38.While welcoming the adoption of the new Family Code, that raised the marriage age to 18 years, and the State party’s efforts to enforce the prohibition of polygamy, the Committee is concerned about the persistence of polygamy and notes the absence of legal provisions governing de facto unions, which may deny women protection and redress in cases of separation.
39. The Committee recommends that the State party:
(a) Strengthen its enforcement efforts in abolishing polygamy, in line with the Committee’s general recommendation No.21 (1994) on equality in marriage and family relations;
(b) Consider reviewing the Family Code (2012) with a view to extending existing legal provisions to couples living in de facto unions.
40.The Committee is concerned at the general lack of available recent data provided by the State party. The Committee is further concerned that GenStat statistics, even though collected by the State party, are not available to the public. It notes that updated disaggregated data by sex, age, race, ethnicity, geographical location and socioeconomic background are necessary for an accurate assessment of the situation of women, to determine whether they suffer from discrimination, for informed and targeted policymaking, and for the systematic monitoring and evaluation of progress achieved towards the realization of women’s substantive equality with regard to all areas covered by the Convention.
41. The Committee calls upon the State party to enhance the collection, analysis and dissemination of comprehensive data disaggregated by sex, age, race, ethnicity, location and socio-economic background, and of measurable indicators to assess trends in the situation of women and progress towards the realization of women’s substantive equality in all areas covered by the Convention. In this regard, it draws the State party’s attention to the Committee’s general recommendation No. 9 (1989) on statistical data concerning the situation of women and encourages the State party to develop gender-sensitive indicators which could be used in the formulation, implementation, monitoring and evaluation and, if necessary, review of women’s and gender equality policies.
Amendment to article 20, paragraph 1, of the Convention
42. The Committee encourages the State party to accelerate the acceptance of the amendment to article 20, paragraph 1, of the Convention concerning the meeting time of the Committee.
Beijing Declaration and Platform for Action
43. The Committee urges the State party, in the implementation of its obligations under the Convention, to fully utilize the Beijing Declaration and Platform for Action, which reinforce the provisions of the Convention, and requests the State party to include information thereon in its next periodic report.
Millennium Development Goals
44. The Committee emphasizes that full and effective implementation of the Convention is indispensable for achieving the Millennium Development Goals. It calls for the integration of a gender perspective and an explicit reflection of the provisions of the Convention in all efforts aimed at the achievement of the Millennium Development Goals and requests the State party to include information thereon in its next periodic report.
45. The Committee requests the wide dissemination in Turkmenistan of the present concluding observations in order to make the people, G overnment officials, politicians, parliamentarians and women’s and human rights organizations, aware of the steps that h ave been taken to ensure the de jure and de facto equality of women and the further steps that are required in this regard. The Committee recommends that the dissemination extend to the local community level. The State party is encouraged to organize a series of meetings to discuss progress achieved in the implementation of the present observations. The Committee requests the State party to continue to disseminate widely, in particular to women’s and human rights organizations, the Committee’s general recommendations, the Beijing Declaration and Platform for Action and the outcome of the twenty-third special session of the General Assembly on the theme “Women 2000: gender equality, development and peace for the twenty-first century”. .
Ratification of other treaties
46. The Committee notes that the adherence of the State party to the nine major international human rights instruments would enhance the enjoyment by women of their human rights and fundamental freedoms in all aspects of life. The Committee therefore encourages the State party to consider ratifying the treaties to which it is not yet a party, i.e. the International Convention on the Protecti on of the Rights of All Migrants and the International Convention for the Protection of All Persons from Enforced Disappearan ce .
47. The Committee recommends that the State party consider seeking cooperation and technical assistance in the development and implementation of a comprehensive programme aimed at the implementation of the above recommendations and the Convention as a whole. The Committee also calls on the State party to strengthen further its cooperation with specialized agencies and programmes of the United Nations system, including the United Nations Entity for Gender Equality and the Empowerment of Women (UN-Women), the United Nations Statistics Division, the United Nations Development Programme, the United Nations Children’s Fund, the United Nations Population Fund, the World Health Organization, and the Office of the United Nations High Commissioner for Human Rights .
Follow-up to concluding observations
48. The Committee requests the S tate party to provide, within two years, written information on the steps undertaken to implement the recommendations c ontained in paragraphs 15 and 23 above .
Preparation of the next report
49. The Committee requests the State party to ensure the participation of all ministries and public bodies in the preparation of its next periodic report, and to consult a variety of women’s and human rights organizations during that phase .
50. The Committee requests the State party to respond to concerns expressed in the present concluding observations in its next periodic report under article 18 of the Convention. The Committee invites the State party to submit its next periodic report in October 2016 .
51. The Committee invites the State party to follow the h armonized guidelines on reporting under the international human rights treaties, including the guidelines on a common core document and treaty-specific documents approved at the fifth Inter-Committee Meeting of the human rights treaty bodies in June 2006 ( HRI/GEN/2/Rev.6, chap. I) . The treaty-specific reporting guidelines, adopted by the Committee at its fortieth session, in January 2008 (A/63/38, part one, annex I) , must be applied in conjunction with the harmonized reporting guidelines on a common core document. Together they constitute the harmonized guidelines on reporting under the Convention on the Elimination of all forms of Discrimination against Women. The treaty-specific document should be limited to 40 pages, while the common core document should not exceed 80 pages.